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Privacy Policy and Notice

FOR EU/UK EMPLOYEES, CONTRACTORS AND APPLICANTS

Introduction :

Subex, like all employers, must collect, store and process data relating to its employees, contractors and applicants in order to manage the employment relationship or potential employment relationship. Subex is committed to being transparent regarding how it collects and uses that data and is committed to meeting its data protection obligations.

What information does Subex collect?

Subex collects and processes a range of information about you and the list of such data may seem lengthy at first glance. However, you will quickly understand that such data is necessary to properly manage the employment relationship with you and is of the type of data normally processed by employers. The types of data may include:

  • your name, address and contact details, including email address and telephone number, date of birth and gender;
  • the terms and conditions of your employment;
  • details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with Subex;
  • information about your remuneration, including entitlement to benefits such as pensions or insurance cover;
  • details of your bank account and national insurance number;
  • information about your marital status, next of kin, dependents and emergency contacts;
  • information about your nationality and entitlement to work in the UK;
  • information about your criminal record;
  • details of your schedule (days of work and working hours) and attendance at work;
  • details of periods of leave taken by you, including holiday, sickness absence, family leave and sabbaticals, and the reasons for the leave;
  • details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence;

assessments of your performance, including appraisals, performance reviews and ratings, training

  • you have participated in, performance improvement plans and related correspondence;
  • information about medical or health conditions, including whether or not you have a disability for which Subex needs to make reasonable adjustments;
  • details of trade union membership; and
  • equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

Subex collects this information in a variety of ways. For example, data is collected through application forms, CVs or resumes; obtained from your passport or other identity documents such as your driving licence; from forms completed by you at the start of or during employment (such as benefit nomination forms); from correspondence with you; or through interviews, meetings or other assessments.

In some cases, Subex collects personal data about you from third parties, such as references supplied by former employers, information from employment background check providers, information from credit reference agencies and information from criminal records checks permitted by law.

Data is stored in a range of different places, including in your personnel file, in Subex’s HR management systems and in other IT systems (including Subex’s email system).

Why does Subex process personal data?

Subex needs to process data to enter into an employment contract with you and to meet its obligations under your employment contract. For example, it needs to process your data to provide you with an employment contract, to pay you in accordance with your employment contract and to administer benefit and insurance entitlements.

In some cases, Subex needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee’s entitlement to work in the country of employment, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled. For certain positions, it is necessary to carry out criminal records checks to ensure that individuals are permitted to undertake the role in question.

In other cases, Subex has a legitimate interest in processing personal data before, during and after the end of the employment relationship. Processing employee/applicant data allows Subex to:

  • run recruitment and promotion processes;
  • maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights;
  • operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace;
  • operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes;
  • operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled;
  • obtain occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled;
  • operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that Subex complies with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled;
  • ensure effective general HR and business administration;
  • provide references on request for current or former employees;
  • respond to and defend against legal claims; and
  • maintain and promote equality in the workplace.

Where Subex relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

If we keep certain special categories of personal data, such as information about health or medical conditions, it is processed to carry out employment law obligations (such as those in relation to employees with disabilities and for health and safety purposes).

Where Subex processes other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring.

Who has access to data?

Your information will be shared internally within the Subex companies, including with members of the HR and recruitment team (including payroll), your line manager, managers in the business area in which you work and IT staff if access to the data is necessary for performance of their roles.

Subex shares your data with third parties in order to obtain pre-employment references from other employers, obtain employment background checks from third-party providers and obtain necessary criminal records checks. Subex may also share your data with third parties, for example, in the context of a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.

Subex also shares your data with third parties (including Subex (UK) affiliate companies) that process data on its behalf in connection with payroll, the provision of benefits and the provision of occupational health services and travel advisors and travel agencies in connection with your business travel needs.

Your data may be transferred to countries outside the European Economic Area (EEA) to: (a) Subex (UK) affiliate companies to allow management, accounting and finance and HR at the affiliates to process the data for purposes as specified above; and (b) to third parties such as travel agencies and travel companies to allow services to be provided to you. Data is transferred outside the EEA on the basis of Data Processing Agreements including Standard Contractual Clauses.

How does Subex protect data?

Subex takes the security of your data seriously. Subex has internal policies and controls in place to mitigate the risk of your data being lost, accidentally destroyed, misused or disclosed, and or accessed except as outlined in this policy/

Where Subex engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

For how long does Subex keep data?

Subex will generally hold your personal data for the duration of your employment and for seven years following the end of your employment.

Your rights

As a data subject, you have a number of rights which may include the right to:

  • access and obtain a copy of your data on request;
  • require Subex to change incorrect or incomplete data;
  • require Subex to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your data where Subex is relying on its legitimate interests as the legal ground for processing; and
  • ask Subex to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override Subex’s legitimate grounds for processing data.

If you would like to exercise any of these rights or have concerns on whether Subex has complied with the law, please contact the Subex Data Protection Officer whose contact information is at the end of this policy.

If you believe that Subex has not complied with your data protection rights, you may also contact the Information Commissioner.

What if you do not provide personal data?

You have some obligations under your employment contract to provide Subex with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide Subex with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.

Certain information, such as contact details, your right to work in the UK and payment details, have to be provided to enable Subex to enter a contract of employment with you, to process payment of your salary and to administer certain benefits. If you do not provide other information, this will hinder Subex’s ability to administer the rights and obligations arising as a result of the employment relationship efficiently.

Is Automated decision-making employed using your personal data?

No, decisions are not based solely on automated decision-making.

Who can I contact for more information?

Subex (UK) Limited (“Subex”) is the data controller for the data discussed in this policy. Subex’s mailing address is 1st Floor, Rama, 17 St Ann’s Road, Harrow, Middlesex, HA1 1JU UK. You may also contact your HR representative or the Data Protection Officer whose contact details are set out below.

Effective 25 May 2018

Data Protection Officer:

GDPR-DPO@subex.com

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